Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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HC determined that petitioners improperly engaged in forum shopping by filing a second petition challenging ICICI Bank's fraud classification of their accounts. Since petitioners' transactions, OTS proposals, and communications occurred with ICICI's New Delhi branch, and initial writ petition was filed in Delhi HC, the cause of action clearly fell within Delhi HC's territorial jurisdiction. Despite petitioners' attempts to justify filing in another jurisdiction based on bank's corporate office location, the forum conveniens was conclusively Delhi HC. The petition was disposed of, directing petitioners to pursue their grievances before the appropriate forum of Delhi HC.
HC determined that petitioners improperly engaged in forum shopping by filing a second petition challenging ICICI Bank's fraud classification of their accounts. Since petitioners' transactions, OTS proposals, and communications occurred with ICICI's New Delhi branch, and initial writ petition was filed in Delhi HC, the cause of action clearly fell within Delhi HC's territorial jurisdiction. Despite petitioners' attempts to justify filing in another jurisdiction based on bank's corporate office location, the forum conveniens was conclusively Delhi HC. The petition was disposed of, directing petitioners to pursue their grievances before the appropriate forum of Delhi HC.
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